Revenue eBrief No. 251/25

30 December 2025

Stamp Duty - Market cap exemption

Finance Act 2025 provided for the introduction of a new exemption from Stamp Duty on certain transfers of stocks and marketable securities (“relevant securities”), which is provided for by section 86B of the Stamp Duties Consolidation Act 1999.

A transfer of relevant securities will qualify for the exemption if:

• at the date of execution of the transfer, the relevant securities are admitted to trading to a regulated market, a multilateral trading facility (MTF) or a market outside the European Union which is equivalent to a regulated market or MTF,
• the closing market capitalisation of the entity that issued the relevant securities was less than €1 billion as of 1 December in the previous year, and
• the transfer is executed during an exemption period, the start and end dates of which are determined by when a valid notification in respect of the market capitalisation was made to Revenue. 

Where the relevant securities were admitted to trading after 1 December of the previous year, the exemption may still apply if the expected market capitalisation of the issuer upon admission to trading of the relevant securities was under €1 billion.

The exemption will apply to a transfer of relevant securities executed between 1 January 2026 and 31 December 2030, where the qualifying conditions are met.

Detailed guidance on the application of section 86B is now available in Stamp Duty Manual Part 7: Section 86B - Market capitalisation exemption.